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Since 2017 the French government has decided to work with B2G electronic invoicing requirements. As from July 2024 on the regulations for B2B and B2C started to change and is planning to use of the eInvoicing and eReporting requirements. In the next sections, we will briefly explain what the new requirements are and what SAP will offer in order to comply with them.
When do companies need to comply with the e-Invoicing and e-Reporting regulations in France?
The French government has decided that every business in France or businesses which have a VAT number in France, should be able to receive e-Invoices from 1 September 2026. This is not based on the size of the company. Sending e-Invoices or performing e-Reporting depends on the size of the company:
1. September 2026: Large businesses
- Annual turnover is bigger than 1,5 Billion Euros
- Balance sheet is higher than 2 Billion Euros
- The company employs more than 5000 employees
2. September 2026: Medium-sized businesses
- Annual turnover is between 50 Million Euros and 1,5 Billion Euros
- Balance sheet is between 43 Million Euros and 2 Billion Euros
- The company employs between 250 and 5000 employees
3. September 2027: small businesses
- Annual turnover is lower than 50 Million Euros
- Balance sheet is lower than 43 Million Euros
- The company employs between 10 and 250 employees
Companies that only sell supplies of goods or services with tax exemption such as specific insurance and banking services, medical and health services and educational services are exempt from the electronic invoicing and electronic reporting requirements. All companies with activities other than the ones previously mentioned, need to comply with the new electronic requirements.
Process scenarios
The government or DGFiP (Direction Générale des Finances Publiques) decided to use two platforms which can connect to each other or work separately. One of them is the PDP (Plateforme de Dématerialisation Partenaire). This is a 3rd party such as SAP and it is optional to use. The PDP can transform the invoices into the required XML format and send it to the platform PPF (Portail Public de Facturation) or the Chorus Pro.
The PPF is then linked to the tax authorities, so connecting to the PDP is optional. Connection to the PPF is mandatory and can be either directly or via the PDP. This may all seem complicated, although the scheme below will clear out most of the questions there might be. The French government has chosen for a Y-Model with two options.
In general the Y-Model for is represented as follows and will result in four options for e-Invoicing:
Option 1
- The supplier 1 creates the invoice or XML and sends this to PDP A.
- SAP sends the XML to the PPF.
- The PPF processes the XML and sends it to the Tax Authorities to get an approval and a signed XML.
- The signed XML will be sent back from the PPF to PDP B.
- PDP B sends this on his turn to buyer 1.
- Meanwhile PDP A (SAP) can send the XML or invoice as well to the PDP B which communicates with buyer 1.
Option 2
- The supplier 1 creates the invoice and XML in SAP which works as a PDP.
- SAP sends the XML to the PPF.
- The PPF processes the XML and sends it to the Tax Authorities to get an approval and a signed XML.
- The signed XML will be sent back from the PPF directly to the buyer 2.
E-Reporting
E-Reporting has a similar Y-Model:
- The supplier 1 or company B (B2B international or B2C) creates the report or XML and sends this to PDP A (SAP) or B.
- PDP A (SAP) or B converts if necessary the report to the required XML format and sends the XML to the PPF.
- The PPF processes the XML and sends it to the Tax Authorities to get an approval and a signed XML.
Digital format used (XML format)
France has chosen to accept different XML formats for electronic invoicing. The possible options all comply with the European standard for electronic invoicing (EN16931), namely:
- Factur-X
- UBL 2.0 (Universal Business Language)
- CII (Cross Industry invoice)
SAP Solution
To be able to work with electronic invoicing and electronic reporting, SAP provides the document and reporting compliance solution. This SAP solution can be integrated into the SAP ECC and SAP S/HANA system. The solution is compliant with the country-specific legal requirements of the available solutions worldwide, such as Italy, Spain, Türkiye, Mexico, France and many more. All the electronic documents of the different countries can be found and managed in the eDocument Cockpit. From this point, you can access the documents, view the XML and/or PDF file and send it to or receive it from the third party or government. Depending on the country, other actions are available. For France, the electronic invoices and electronic reports will be accessible in the eDocument Cockpit where further steps can be undertaken. This means that the solution can provide an end-to-end solution which automatically generates the required XML file based on the information from the created documents in SD or FI.
After sending the XML, it passes through document and reporting compliance cloud edition on to the tax authority platform of the government. Here the XML will be signed.
In France, SAP will connect to the PPF directly. This means that no connection is needed with a third party. More information will be provided about the SAP solution end of February 2026 when the SAP solution will be released.
Why should a company comply with the electronic regulations?
When a company does not comply with the electronic regulations, it receives fines. The fine runs from 15 Euros per invoice to an annual maximum between 15.000 to 45.000 for invoices. The fines for reporting are between 250 and 750 Euros per transmission to an annual maximum between 15.000 to 45.000 Euros for transmissions. Therefore it is important to make sure to comply with the French electronic regulations.
How PIKON can help you
With our Competence Center for Legal Requirements, we are a strategic partner who ensures that your SAP system and business processes meet different country-specific legal requirements all over the world in the long run. We have a team of experts that combine SAP expertise and in-depth knowledge of the end-to-end legal process and technical requirements of the Spanish and many other eInvoicing and eAccounting regulations. We have gathered this experience through our many SAP Document & Reporting Compliance and local implementation projects all around the world. Some examples are SDI in Italy, SII in Spain, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, XRechnung in Germany, the different legal requirements in Turkey, etc. We have also developed our own compliance SAP Add-Ons e.g. MTD VAT in the UK and the VAT Whitelist in Poland. Furthermore, we always keep an eye on new and changing legal requirements and inform our customers when action is needed. This ensures that your company doesn’t need to follow up on all the legal requirements yourselves, and you can concentrate on your daily business.
